Patron Wills Ltd (“We”) are committed to protecting and respecting your privacy.
This privacy notice provides you with details of how we collect and process your personal data, including any information you may supply us.
By providing us with your data, you warrant to us that you are over 13 years of age.
Patron Wills Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
2). WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, marital status, title, date of birth, gender, NIC number, Tax Reference/s, VAT number and Company number
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of payments to third parties made by you.
- Technical Data may include data held by us necessary for the preparation of books and accounts, payroll, VAT submissions, tax returns and confirmation statements.
- Usage Data may include information about how you use our services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of our clients who use a specific aspect of our service. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract. If you don’t provide us with the requested data, we may have to cancel a service you have requested, but if we do, we will notify you at the time.
3). HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms or by communicating with us by post, phone, email or otherwise, including when you:
- order our services;
- subscribe to our service or publications;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below
- Identity and Contact Data from publicly availably sources such as Companies House, HMRC and the Electoral Register based inside the EU.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, Facebook Messenger or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org
4). Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/ Activity||Type of Data||Lawful basis for processing|
|To register you as a new customer||a) Identity b) Contact||To enable us to perform a contract with you|
|To process and perform the contract between us.||a) Identity b) Contact c)Financial d) Transaction e) Technical||Performance of a contract with you|
|Manage payments, fees and charges||a)Contact data b) Financial data||a) Performance of a contract with you b) Necessary for our legitimate interests to recover debts owed to us|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||a) Identity b) Contact c) Transaction d) Technical e) Usage||Necessary for our legitimate interests to develop our products/services and grow our business|
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at firstname.lastname@example.org at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
6). DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
7). DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8). DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9). YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To make this site simpler, small data files are placed on your computer. These are known as cookies. Most big websites do this too.
They improve things by:
- remembering settings, so you don’t have to keep re-entering them whenever you visit a new page;
- remembering information you’ve given (e.g. your postcode) so you don’t need to keep entering it;
- measuring how you use the website so we can make sure it meets your needs.
Our cookies aren’t used to identify you personally. They’re just here to make the site work better for you. Indeed, you can manage and/or delete these small files as you wish.
You can opt out of Google Analytics cookies for all sites.
To learn more about cookies and how to manage them, visit AboutCookies.org.
i) First Party Cookies
These are cookies that are set by this website directly.
ii) Third Party Cookies
These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by Twitter, Facebook and Google+. If you want to prevent sites setting third party cookies, instructions to do so are here (access through website only).
iii) Log Files
Log files allow us to record visitors’ use of the site. These logs are automatically generated from all our visitors, which we use to make improvements to the layout of the site and to the information in it, based on the way that visitors move around it. Log files do not contain any personal information about you.
Links to other websites
Our website contains links to our partners, as well as other external sites. You should note, that if you click through to any of these external sites, we do not have control over that site. We cannot be responsible for the protection of any information that you provide to these other websites as they are not governed by this privacy statement. You should always exercise caution and look at the privacy statement of whichever website it is that you are visiting.